Monthly Archives: March 2015

Hard Hats

Hard hats are built to meet ANSI standards for impact. All modern (fiber and resin and plastic) hard hats are date code stamped inside the hat. Don’t do anything to void the manufacturer’s warranty. This may include painting it and even applying adhesive stickers. Sunlight can play havoc on the durability and impact resistance of plastic hard hats. Plan on changing out hard hats at intervals based on the use and age of the hat. If your plastic hard hat shows signs of brittleness such as hairline cracks or will crack or chip if bent, it’s time to replace it. At a minimum, replace the hard hat per the manufacturer’s recommendation.

Don’t attach tools or work items to your hard hat such as a clip-on tape measure, spring clamps, Chicago fitting pins, pencils, etc. If an object falls on your hat, you don’t want anything on it that might hang-up the falling object or in turn fall off and hit you.

In the field, we commonly see people wearing duck bill hard hats backward. Even if you have attached the hat suspension backward in the hat so the brim faces over your neck instead of your nose, the hat will not provide the protection that it was designed to. The brim is there to protect your face and the nose on it. Without a brim there, you may be more liable to receive a face injury. Now, welders commonly wear their duck bill hard hat backward so they can also wear a welding mask. However, OSHA frowns on that practice. Practically speaking, if not welding or a similar task where the use of a front-facing hard hat bill is mutually exclusive, then hard hats should be worn with the brim facing forward. There are specially designed duck bill suspensions that allow you to easily and quickly rotate the hat from bill forward to back and front again as needed. Keep in mind that the brim can protect the face and nose from injury from falling objects and if you wear a hard hat reversed with no other means of face protection, then you are probably at greater risk of injury compared to the person wearing the hard hat correctly.

Operating Man Lifts

While OSHA does not require fall protection PPE for the in-basket operator of a vertical scissor lift, it is required in the basket of a boom lift. But far too often in-basket operators of boom lifts fail to use fall protection PPE or tie off to approved and engineered attachment points.

Another problem is operators using a boom lift as if it were a crane and hoisting materials with the basket.  If it does not fit in the basket or the load exceeds the rated capacity of the lift, don’t put it in the basket and never hoist materials dangling over the side of a basket! Another no-no: don’t tie off the boom and/or basket to another object. Remember to read, understand and follow the manufacturer’s recommendations for inspection, maintenance and operation of the equipment.

Regarding boom lifts, we also find that employees may fail to demonstrate operation competence but are allowed to use the equipment anyway. And another item is failing to inspect the equipment before use. Typically, the lift will include a manufacturer’s inspection checklist. The checklist will most often include checking the man lift to boom knuckle bolts, hydraulic fluid level, hoses, and other critical features. We’ll cover man lifts in more detail in an upcoming post.

Fall Protection

Falls account for a significant number of injuries and fatalities nationwide. In the work environment, OSHA requires that fall protection is provided at elevations of four feet and higher in general industry, 5 foot and higher in the maritime industry and six feet and higher in the construction industry.

For more information see:

Although the need for fall protection may be apparent, you still should assess task hazards with a job hazard analysis (JHA) or similar assessment tool to better determine what type of fall protection is needed to protect workers.

Using the OSHA hierarchy, first remove the hazard if possible and/or re-design the task(s) so that employees are not exposed to the hazard. If this can’t be done or is not fully effective, then install engineering controls such as guard rails and other features to physically prevent a fall from one level to a lower level. When all else fails, then you may employ PPE (personal protective equipment) to protect the worker. Use a JHA to document your assessment determination; it becomes your reference point and proof of concept.

When managing a work environment with fall hazards, as applicable, be sure to incorporate these aspects:

  1. provide and maintain fall protection equipment;
  2. engineer, install and/or maintain  fall protection devices such as railings;
  3. train employee on the use and care of fall protection PPE;
  4. use approved designated and/or engineered fall protection attachment points;
  5. inspect fall protection PPE;
  6. remove damaged fall protection equipment and/or PPE from service;
  7. properly manage and document fall protection equipment put into service;
  8. properly wear and adjust fall protection PPE;
  9. maintain 100 percent tie-off when using fall protection PPE;
  10. wear fall protection PPE while in boom lift baskets and other aerial work platforms.

This list is not intended to be all inclusive. As an employer, the onus is on you to provide a safe and health workplace for your employees.

From our experience, while violations occur across industries, residential and commercial construction are typically especially problematic. Another problem area is failing to wear fall protection PPE while operating man lifts. We’ll cover man lifts in more detail in another post shortly.

What Makes an EH&S Management System Successful?

Review your company processes and culture to see if any of the attributes or pitfalls noted here apply.

Having examined hundreds of business cultures related to Environmental Health & Safety (EH&S) management systems, I have discovered common elements that crop up in companies seemingly forever behind the curve. Despite this you’d be hard pressed to find a company that says that workplace safety and environmental compliance are not a priority. So how and why do some companies do so much better than others? Let’s take a step back at examine some building blocks.

Because systems run on people power, there should be compelling evidence that a system values the importance of treating all people – be they employees, customers or vendors – in an evolved and humanistic manner. As such, the culture should cultivate thoughtful communication.

It is fair to say then that organizations therefore run on communication, and if that aspect proves ineffective, that may be an indicator of other shortcomings. Now, senior management must not only communicate belief in EH&S compliance, but must allocate adequate resources to ensure that this aspect can be managed successfully. More than that, they must exhibit consistent and visible support for EH&S.

So far as EH&S management, success is built upon cultivating desired behaviors. For that to work, besides effective communication, there must be consequences for failing to meet desired goals and objectives. If the trend is to reward project completion and productivity goals without best considering the costs of failing to meet environmental and occupational health and safety objectives, the path to compliance will be difficult.

Some companies change management models and modes too frequently; too easily swayed by the latest jargon or program. Or, they may lose steam as management is shuffled or distracted. Employees notice when management is not committed to EH&S or tends to “change colors” as politics or other demands influence them. By then, it’s more difficult to gain employee buy-in. Stay consistent and tweak when necessary. Keep stakeholders in the loop to cultivate appreciation and compliance. Investment in EH&S goals and objectives requires commitment and patience.


The role of the EH&S professional should be seen as value added. There are parallels between EH&S management and quality management. Give them the authority, respect and resources necessary to do their job. Be careful who you select to administer EH&S. Think of all the companies over the years who have paid hefty fines or made the news in unbecoming ways because their EH&S professionals were leveraged to make inappropriate decisions or just did not have effective skills or knowledge. The EH&S professional should be given ample autonomy, and report to appropriate management within the organization. Examine your current reporting structure. Does it give the appearance of a potential conflict of interest? Be certain that the reporting structure won’t cause the EH&S professional to feel pressured to make decisions that favor production or another aspect at the expense of EH&S compliance.

Definition of Solid Waste (DSW) Rulemakings for RCRA Hazardous Waste Regulations

2015 DSW Final Rule

The EPA finalized new safeguards that promote responsible hazardous secondary materials recycling. The final rule modifies the EPA’s 2008 Definition of Solid Waste (DSW) rule to ensure it protects human health and the environment from the mismanagement of hazardous secondary materials intended for recycling, while promoting sustainability through the encouragement of safe and environmentally responsible recycling of such materials. The EPA has also issued a PDF document that explains the 2015 DSW Final Rule. It is available at the link below.

More information is located at the EPA web site:

Skip to toolbar